1. Implementation of the Revised Branch Technical Position on Concentration Averaging and Encapsulation
A. Christianne Ridge
Division of Decommissioning, Uranium Recovery, and Waste Programs
Office of Nuclear Material Safety and Safeguards
Low-Level Radioactive Waste Forum
Spring 2016 Meeting
April 14, 2016

2. Outline
Training with Agreement States and NRC Regions and participation in EPRI working group
Public Q&A based on training and working group participation
Federal Register Notice (FRN) on Contaminated Materials and Public Comments
Next steps

3. Background
10 CFR 61.55(a)(8) allows averaging over volume or weight of waste
The Concentration Averaging and Encapsulation Branch Technical Position (CA BTP) provides guidance to address potential “hot spots” in waste containers
Revised CA BTP was issued on February 25, 2015, Federal Register Vol. 80, No. 37, 10165

4. Training
BTP authors offered training to Agreement State partners and NRC regional staff
Training slides are publicly available on the NRC CA BTP website:

5. EPRI Working Group Participation
EPRI presentation today on working group
NRC participation limited to clarification of positions in the CA BTP and did not result in regulatory decisions or commitments
NRC clarifications made to working group are publicly available as Q&A on the NRC CA BTP website

6. Q&A
NRC committed to making Q&A gathered from training sessions and stakeholders publicly available
First batch of Q&A made publicly available on 10/30/ Additional Q&A added on 2/18/2016 and 3/2/2016
Updates have been limited to additions and have not changed previously-published Q&A

7. Q&A – Waste Types & Streams
Several questions related to the relationship between waste types and waste streams
For the purposes of the CA BTP
Waste types based on physical characteristics
Waste streams based on physical and radiological characteristics
Guidance for blendable waste (e.g., resins, soils, contaminated trash) relies on distinctions between waste types and waste streams

8. Q&A – Waste Types & Streams
Several questions related to the relationship between waste types and waste streams
For the purposes of the CA BTP
Waste types based on physical characteristics
Waste streams based on physical and radiological characteristics
Guidance for blendable waste (e.g., resins, soils, contaminated trash) relies on distinctions between waste types and waste streams

9. Q&A – Waste Types & Streams (continued)
Q: Given that Revision 1 of the CA BTP relies on the Uniform Waste Manifest (UWM) to identify waste types, can anion and cation exchange resins be considered a single waste type even though they are listed on the UWM separately? A: Yes. Anion and cation resins need not be treated as separate waste types for the purposes of the CA BTP. Similarly, for the purposes of the CA BTP, a bed of mixed ion exchange media is considered a single waste type (even when charcoal is a constituent of the mixed bed).

10. Q&A – Waste Types & Streams (continued)
Q: Guidance for mixing blendable waste types only discusses physical and chemical compatibility of the waste types. What are the averaging constraints for mixtures of two or more blendable waste types? A: Once physical and chemical compatibility are shown, the separate waste types can be treated as one waste type. The guidance for combining separate waste streams of the same waste type applies.

11. Q&A – Waste Types & Streams (continued)
Q: The CA BTP includes a provision for combining waste streams at a generator’s facility for operational efficiency, occupational safety, or occupational dose reduction, but the CA BTP specifies it applies only to wastes of the same waste type. Can it be applied to different waste types? A: Once physical and chemical compatibility are shown, the provision can be used as if the wastes belong to the same waste type.

12. Q&A – Extreme Measures
Q: What does staff interpret as “extreme measures” to avoid when performing solidification or thermal processing? A: As in the 1995 CA BTP, the staff interprets the phrase to mean that any non-radioactive material added to the waste should have a purpose other than lowering the waste classification (e.g., stabilization or thermal process control). As in the 1995 CA BTP, the staff has not specified any particular numerical constraints, and instead gives State regulators flexibility in identifying “extreme measures.”

13. Q&A – Extreme Measures (continued)
Q: Absent a specific numerical standard for “extreme measures,” can the 14 percent waste loading criterion used for encapsulation in containers larger than 0.2 m3 also be used for solidification and thermal processing? A: No. The 14 percent waste loading value is based on a topical report for an encapsulation process submitted to the NRC and is not necessarily transferrable to other processes. The key factor in determining whether a waste loading is appropriate is to determine whether the material added has a purpose other than changing the waste classification. The NRC staff encourages communication with disposal State regulators on these issues.

14. Q&A – Applicability
Q: The revised CA BTP states that its scope is limited to averaging concentrations of radionuclides to determine waste classification for disposal (i.e., per 10 CFR 61.55(a)(8)). Does that mean that the CA BTP does not apply to waste being shipped for processing? A: Yes. The CA BTP does not apply to waste being shipped from a waste generator to a waste processor. The CA BTP applies to waste after it is in final form and is being shipped directly to a licensed waste disposal facility for disposal. Concentration averaging methods are evaluated as part of processors’ licensed activities.

15. Q&A – Encapsulation
Q: The revised CA BTP lists stability as one of the benefits encapsulation can provide but does not address stability as an averaging constraint. Should it? A: Neither the 1995 nor the revised CA BTP states that concentrations should only be averaged if encapsulation provides stability. Class B and C waste must meet the stability requirement of 10 CFR 61.56(b). This requirement may be met by the encapsulating medium or by other means (e.g., disposal in a high integrity container). For Class A waste, the NRC staff did not assume waste stability in calculating hypothetical intrusion doses. Intrusion was assumed to occur at the end of the active institutional control period (i.e., 100 years after site closure), and the intruder was assumed to come into direct contact with the encapsulated waste (i.e., encapsulation was assumed to have failed). Therefore, changing the guidance to state encapsulated Class A waste should provide stability like the 10 CFR 61.56(b) requirements was unnecessary.

16. Contaminated Materials
When the NRC issued the revised CA BTP staff noted that the distinction between contaminated materials and contaminated trash might need further clarification.
NRC published an FRN soliciting public comment on 1/20/2016
Comment period closed on 3/21/2016

17. Contaminated Materials (continued)
NRC received three comment letters
Two letters expressed the view that additional guidance is not necessary
One of those letters also recommended that if any clarification is made, CA BTP Tables 2 and 3 should be used to distinguish between contaminated materials and contaminated trash
One expressed concerns about undocumented chemical waste disposal

18. Next Steps
Determine whether additional guidance is needed for distinguishing contaminated materials from contaminated trash
Provide guidance or explain decision that no additional guidance is needed and address comment letters
Continue to respond to stakeholder questions and publish Q&A on public website

19. Resources CA BTP public website, including Q&A CA BTP in ADAMS
Vol. 1 ML12254B065
Vol. 2 ML12326A611
CA BTP public website, including Q&A
Any Questions contact Maurice Heath or